a quick overview…
TRANSCRIPT
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Bedok Safety Group Seminar13 May 2010
Workplace Safety & Heath (Confined Spaces) Regulations 2009
And
13 May 2010
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Accident Case Studies
A Quick Overview….
Rationale behind the WSH (Confined Spaces) RegulationsThe WSH (Confined Spaces) Regulations largely adopt the existing regulations 25 of GP Regulations. It also upgrade many of the key provisions under CP84 to regulations. In addition, we have also make reference to
The Beginning….
GP Regs 25 CP84International
Regs & StandardsNew dedicated WSH
(CS) Regs
The WSH (CS) Regulations hence is largely a consolidation of the GP Regs 25 and CP 84. Therefore industry should already be familiar with the requirements as they are not new.
pg y y p gsome of the international regulations and standards, where appropriate.
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Key focus is to put in place a systematic and rigorous structure to ensure proper conduct of Risk Assessment and execution of control measures for entry into and safe working in confined spaces
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• PART 1 – Preliminary
New WSH (Confined Spaces) Regulations 2009
Arrangements of Parts
• PART 2 – General Provisions
• PART 3 – Control of Entry into Confined Space
• PART 4 - Miscellaneous
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1. Definitions
2. Application & Coverage
New WSH (Confined Spaces) Regulations 2009
Key Features
pp g
3. Duty-holder for Compliance
4. Definition of Confined Space
5. Record of Confined Space
6. Control of Entry into Confined Space
7. Periodic Testing of Atmosphere
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8. Warning Signs at Entrance of Confined Space
9. Display of Name or Identification Badge
10.Training of Workers & Supervisors
11.Appointment of Confined Space Attendant
12.Establishment of Emergency and Rescue plans® All Rights Reserved
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Confined Space – Means any chamber, tank, manhole,
Confined Spaces - DefinitionRegulation 2 - Definitions
vat, silo, pit, pipe, flue or other enclosed space , in which –
1. Dangerous gases, vapors or fumes are liable to be present to such an extent as to involve a risk of fire or explosion or persons being overcome by the gases, vapors or fumes or
2. The supply of air is inadequate, or is likely to be reduced to be i d t f t i i lif
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inadequate for sustaining life or
3. There is a risk of engulfment by material
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New WSH (Confined Spaces) Regulations 2009
Definitions – Key Legal Persons
• Competent Person – means a person who has sufficient experience and training to perform the work required to be carried out
• Authorised Manager – means an Authorised Manager appointed under regulation 9 and includes any other person appointed to perform the duties of an Authorised Manager by the Responsible Person
• Confined Space Attendant – means a Confined Space Attendant appointed under regulation 22
• Confined Space Entry Permit – means a permit issued under regulation 13
• Confined Space Safety Assessor means a Confined Space Safety Assessor
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• Confined Space Safety Assessor – means a Confined Space Safety Assessor appointed under regulation 9
• Responsible Person – in relation to a person entering or working in a CS, means –
a) His employer; or
b) The principal under whose direction he enters or works in the CS® All Rights Reserved
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New WSH (Confined Spaces) Regulations 2009
Definitions
• “Entry” means ingress by a person into a confined space whichEntry means ingress by a person into a confined space which occurs when the person’s head passes through an opening into the confined space;
• “Hazardous Atmosphere” means an atmosphere where —a) the level of oxygen in the atmosphere is not within the range of
19.5% to 23.5% by volume; b) the level of flammable gas or vapour in the atmosphere is 10%
f it l l i li it
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or more of its lower explosive limit; or c) the levels of toxic substances in the atmosphere exceed the
permissible exposure levels as specified in the First Schedule to the Workplace Safety and Health (General Provisions) Regulations;
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New WSH (Confined Spaces) Regulations 2009
Key Features2. Application and Coverage
Apply to all workplaces as specified in the First pp y p pSchedule of the WSH Act.
3. Duty-Holder for ComplianceEmployer or Principal (Responsible Person) largely responsible for complianceOccupier responsible for issues affecting
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physical facilities such as record of CS and access / egressSpecific duties also designated to special Individuals eg. CS Assessor, Authorized Manager and the Competent Person.
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4. Definition of Confined Space
New WSH (Confined Spaces) Regulations 2009
Key Features
To include any enclosed space in which there is a risk of engulfment by material.
5. Record of Confined SpaceTo require making a Record of Description and Location of all CS in the factory (for
ll fi d d t ti CS)
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all fixed and stationary CS)To inform persons who are liable to be exposed to the hazards of the CS, of the existence and hazards of the CS.
6 Control of Entry into Confined Space
New WSH (Confined Spaces) Regulations 2009
Key Features
6. Control of Entry into Confined SpaceBefore any entry into a CS, duty of Responsible Person to ensure
Implementation of CS Entry Permit (CSEP)Appointment of CS Assessor, Authorized ManagerEvaluation of necessity for entry or work in the CSEnsure that CSEP has been issued which specifies:
• Description and location of the CS
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• Description and location of the CS• Purpose of entry into CS• Results of gas testing of the atmosphere of the CS• Validity period for the CSEP
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New WSH (Confined Spaces) Regulations 2009
Key Features
6. Confined Space Entry Permit (CSEP)
CSEP system comprise the following steps
Application of CSEP by the Supervisor
Evaluation of CSEP by the CS Assessor
Conduct testing of atmosphere of the CS
Endorse the CSEP and forward to Authorized Manager
Issuance of the CSEP by Authorized Manager on satisfaction that
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y gentry into or work in the CS can be carried out with due regard to safety and health of persons
Posting of the CSEP at the entrance to the CS
Monitoring to ensure safety and health of worker during entry into or work in the CS.
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New WSH (Confined Spaces) Regulations 2009
Key Features
7. Periodic Testing of Atmosphere
CS Assessor to test the atmosphere of the CS at periodic intervals
If there are 2 or more persons in the CS, at least one of them continuously monitor the atmosphere in the CS with a suitable gas detector
If hazardous atmosphere detected by the tests or continuous monitoring,
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monitoring,
All persons in the CS must vacate immediately
An evaluation is made to determine how the hazardous atmosphere developed
No person shall re-enter the CS until a new CSEP is issued by the Authorized Manager
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New WSH (Confined Spaces) Regulations 2009
Key Features
8. Warning Sign at Entrance of CSOccupier to clearly post a Notice at the entrance to the CS to warn persons of the hazards of the CS
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9. Display of Name or Identification BadgeOccupier to clearly post a notice at the entrance to the CS to warn persons of the hazards of the CS
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10.Training of Workers and Supervisors
New WSH (Confined Spaces) Regulations 2009
Key Features
Specific mandatory training requirements for workers and supervisors working in a CS.
11. Appointment of Confined Space Attendant The appointment of a Confined Space Attendant whenever entry into work is
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ycarried out in CS.
12.Establishment of Emergency and Rescue Plan To ensure prompt and safe recovery of personnel during accidents in CS
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Confined SpaceConfined SpaceConfined Space Confined Space
Accident Case StudiesAccident Case Studies
• Food flavorings manufacturing factory
Case 1 : Case 1 : Toxic Poisoning in FoodToxic Poisoning in Food ReactorReactorCase 1 : Case 1 : Toxic Poisoning in FoodToxic Poisoning in Food ReactorReactor
g y
• Accident occurred in a thermal reactor / mixer standing at 1.8 m tall
O k kill d h• One worker killed when he was washing the interior of the reactor
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• Reactor use to mix food grade products in elevated temperature
Case 1 : Case 1 : BackgroundBackgroundCase 1 : Case 1 : BackgroundBackground
Interior of thermal reactor
temperature
• Worker tasked to wash the interior of the reactor from the outside using a high pressure water jet
• Worker was found dead with body half inside the reactor
High pressure water-jet® All Rights Reserved
• Worker need not enter into reactor
• Burn patches found inside
Case 1 : Case 1 : FindingsFindingsCase 1 : Case 1 : FindingsFindings
Interior of thermal reactor
• Burn patches found inside the tank. Presumably worker tried to enter and remove the patches
• Concentration of hydrogen sulphide (H2S) detected within the tank.
• H2S could be formed under high temperature reaction High pressure
water-jet
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• There was no risk assessment done
• Occupier did not consider there was a need* to enter into tank, thus:
Case 1 : Case 1 : FindingsFindingsCase 1 : Case 1 : FindingsFindings
– There was no SWP / entry permit – There was no gas testing/ventilation– There was no emergency respond plan / equipment
* interviewing of workers revealed that previous entry has been made before and mgmt knew such a problem existed
• Worker was new to the job. No training / information on the hazards and risk was given.
• No means to prevent unauthorised entry
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• Chemical industry in
Case Case 2 2 : : Explosion from Chemical Storage Explosion from Chemical Storage TankTank
Case Case 2 2 : : Explosion from Chemical Storage Explosion from Chemical Storage TankTank
lubrication oil manufacturing
• Accident occurred at a chemical storage tank
• Two workers killed and two injured when they were washing the interior of the tank
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• The tank was emptied of content (lubricating oil) and rinsed with xylene
Case 3 : Case 3 : BackgroundBackgroundCase 3 : Case 3 : BackgroundBackground
• Two workers was to clean the tank by hydro jetting the interior while standing on the outside
• A spark caused by the hydro• A spark caused by the hydro jet hitting against the wall of the tank initiated an explosion, killing two and injured another two working nearby
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• Tank was not purged or ventilated after being rinsed with solvent. Presumably, the xylenevapourised and formed a flammable mixture
Case 3 : Case 3 : FindingsFindingsCase 3 : Case 3 : FindingsFindings
• Adjacent tank measured with > 100% LEL
• No measures in place– There was no risk assessment conducted– There was no gas testing to determine the
level of flammability inside the tanklevel of flammability inside the tank– There was no ventilation – No consideration for usage of proper
equipment (e.g. explosion proof / intrinsically safe)
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Confined Space
Mechanical Ventilation
Risk Assessment
Gas Testing
Where were the gaps?Where were the gaps?
F t lF t l
Confined Space Entry Permit
No forced ventilation provided
No RA conducted & no safe work procedure
N t ti Fatal Fatal AccidentAccident
Swiss Cheese ModelSwiss Cheese ModelNo CSEP & no CS attendant
No gas testing carried out
Always regard the confined Always regard the confined
Learning Points
space as not safe for entry space as not safe for entry until proven otherwise.until proven otherwise.
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Learning PointsDon’t be a Hero
Never assume that you can carry out rescue with proper rescue equipment and the assistance of others
Identification of CS and evaluation of need to enter
Basic Elements of CSP
Evaluation of risks
of entering/working in
CS
Appointment of
Responsible Personnel
Confined space entry permit system
Training and Information
Emergency Preparedness and rescue
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Be conscious of concentration of airborne contaminantsDo not simply put in blowers and assume that
ventilation provided is adequate. Always conduct gas testing of atmosphere within the confined space.
ConclusionConclusionHazard
Do your Risk AssessmentDo your Risk Assessment
Incident
RealityIdeal
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Do your Risk AssessmentDo your Risk AssessmentBut alsoBut also
RecogniseRecognise the gaps within the gaps within your layers of protectionyour layers of protection
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Resources and Useful References• Ministry of Manpower• www.mom.gov.sg/oshd• Workplace Safety and Health (Confined Spaces) p f y ( f p )
Regulations 2009
• SPRING Singapore• www.spring.gov.sg• CP 84:2000 Code of Practice for entry into and
safety working in confined space
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Resources and Useful References• Workplace Safety and Health Council (WSHC)• www.wshc.sg• Technical Advisory for working safely in y f g f y
confined space• Confined space plan checklist• CS safety guidebook for supervisors and workers• CS posters and stickers• Video on confined space safety
• WorkSafe BC• Guidelines, training videos and • presentations on confined space hazards•http://www2.worksafebc.com/Topics/ConfinedSpaces/Resources.asp
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